On one hand, they appeal to ideals of fairness and inclusivity. On the other, they do not often form the primary basis for court reasoning toward dispute outcomes. A common example is the loss of business that befalls a storefront on the far side of a bridge damaged and made impassable by the negligence of a ship captain on the river below. First, the scope of liability in economic loss cases becomes too large given the speed and fluidity with which such loss spreads through an urban business community.
Second, courts prefer to reserve liability of defendants for more tangible, verifiable personal injury and property damage given the often limited capacity to absorb such liability. If compensation were properly a primary function of the law, neither of these challenges would prevent liability for a party harmed in the purely economic sense. Likewise, social justice is sometimes, though perhaps less rarely, served through tort litigation; when it is, such cases seem to meet a cultural expectation that law occasionally restore power imbalances in our society even apart from other functions.
Such cases might include Grimshaw v. Ford Motor Co. Tort law occasionally serves the functions of compensation and social justice but does so usually to reinforce the other functions listed above. Flint, U. Grimshaw v. CV, WL N. First, all permit social engineering—the act of defining norms not to reproduce a social structure but to reshape one. A lead case, Brzoska v. Given that they were not independently harmed—their health was not made worse—the case turns upon whether a consented touching becomes unconsented and offensive when its circumstances involved greater perceived or actual health risk than originally known.
As a case of optimal deterrence, the case represents a court instructing the public on how it should best assess health risks. For example, a judgment must be made as to the utility of any conduct, and this is weighed against the risks associated therewith. The goal is to deter as much risky behavior as possible before doing so creates a net loss in value to the society. See Brzoska, A. A second theme across the functions of tort law is the priority for balancing interests.
To see this in practice from multiple angles, one might look to a classic nuisance case such as Carpenter v. Double R Cattle Co. First, it showed the court balancing tradition with modernity. The choice to allow Double R to continue its Carpenter, P. Conceivably, on different facts such as greater population density or greater toxicity in the industrial discharge, the case would have come out in favor of Carpenter on each of the above balances.
Under normal conditions in modern, urban environments, this calculus favors individual plaintiffs when institutions, governments, or corporate entities harm them, on the premise that costs of damage awards can be passed on to taxpayers or consumers. However, when such an entity is the only one of its kind, or the sole basis for community subsistence in an isolated area, and where it is unable to pass on such costs without failure, loss distribution dictates that the costs of harm should be borne by the plaintiff.
If social engineering and interest balancing are two common themes across these functions, efficiency is a third. This may take the form of either economic or judicial efficiency. Optimal deterrence and loss distribution say that behavior should be regulated, and costs of injury spread, only to the extent that doing so does not create a net economic burden to a society.
The Supreme Court of Illinois elaborated on the fear of increased litigation: Seigfried, N. The focus at trial would then shift from the drunk driver to the alleged social hosts.
If these functions are to be understood as policy goals, then the common features of those goals—or metafunctions—all appear to allow reshaping the social field by weighing disparate competing interests and resetting their balance to make more efficient use of resources. What, then, is federalism, and can it serve these goals? Politically, it requires leadership and institutions at both levels of authority with clear delineation of the roles and competencies served by each.
In legal terms, federalism requires harmonization of rules and processes between both levels, and such harmonization usually entails designation of supremacy to the federal government in case of disagreements or uncertainties. And culturally, Greenhouse et al. Gwinnell, A. VI, cl. Political contours of American federalism are most apparent. Each state is governed by analogous tripartite branches of executive, judicial, and legislative authority although details and nomenclature within each may differ.
Behind institutions and leadership sits the legal authority through which they operate and regulate behavior. The proper legal dimensions of federalism afford less local autonomy than the distribution of political power that flows from them. These include the power to collect taxes, borrow on credit, regulate transnational and interstate commerce, establish naturalization rules, establish bankruptcy rules, coin money and punish counterfeiting, establish post offices, protect copyrights, establish federal tribunals, punish crimes on the high seas, declare war, raise an army, provide a navy, develop military governance, call upon the military to maintain the Union, arm and discipline the military, See CAL.
Consolidated Freightways Corp. Navajo Freight Lines, Inc. Lopez, in which a federal statute barring guns from school areas was struck down as exceeding the scope of federal commerce power.
Sebelius, where the Roberts Court again reinforced limitation on federal commerce power in the domain of health insurance despite finding federal authority under the taxation clause. If political institutions and leadership are shared between state and federal levels and if legal authority is granted to federal and state bodies on different matters of competence, then these follow from an implicit agreement that cultural matters are also best divided between state and federal levels of governance.
Culture, here, includes all symbols, practices, and belief systems of a society. As it relates to politics and law, culture is the extra-legal array of norms and customs that underpin legal authority and the efficiency by which it regulates a population.
Religion is a second example; the predominance of individual religious communities in certain states of the Union— Mormons in Utah for example—has differentially shaped legal rules in those states where complete national uniformity in the form of federal law might prove untenable or inefficient.
See U. See S. Though the manner in which cultural domains are divided among state and federal authorities may be interpreted differently, the fact of such division can hardly be disputed.
For those who believe federalization is intrinsically a bad thing, tort law has traditionally been comprised of common law rules hailing from customary norms that emerge from community life and social organization. This use of community is problematic for several reasons. First, it taps into nationalist narratives in which a large population of individuals separated by great distances and ideological positions must imagine themselves as descendants of a common folk past.
This is not to suggest uniformity at the level of federal law is preferable but rather that the choice whether or not to federalize an area such as tort law should not be made based upon a mythically common community when its existence is increasingly aspirational rather than empirical. Mormon Church on the Utah State Legislature in the ban of happy hours, among other liquor-related legislation.
See Thelton Henderson, Justice, U. Court, N. These fears are unjustified at the very least because national governments cannot generally—particularly in the United States example—easily govern vastly separated and diverse populations. They rely upon states for collaboration in this effort and must therefore leave in local governments a substantial degree of sovereignty.
Viewed in this light, federalism appears to match the metafunctions of tort law that characterize recognized functions such as optimal deterrence and loss distribution. First, it enables large-scale social engineering— the refinement of a social order in ways that exceed current realities.
Had the Supreme Court chosen to favor community in that example, the nation as a whole might have retained a racially segregated urban landscape for years to come. Second, like other functions, federalism also entails critical balancing of key social and legal interests. At the most general, this takes the form of power balancing. Finally, federalism may be construed as an ongoing quest for efficiency. Many would disagree with this claim by pointing to government See Glenn S. Klass, supra note 15, at , See Lipkin, supra note , at — But the operations of government and the arrangement that leads to its authority are two separate matters.
And again, in certain areas of competence such as overseas military operations or foreign trade, the national government is usually able to act far more effectively. Likewise, the maintenance of city streets or building codes and inspection practices are likely more effective when performed by local policy experts and technicians.
Though it may often get such competence allocations wrong, federalism, here, is the ongoing effort to refine them.
As a process concerned with the distribution of political, legal, and cultural authority between local and national levels of governance, federalism exhibits several of the qualities associated with existing functions of tort law. Cursory review of those functions—corrective justice, optimal deterrence, loss distribution, and to some extent compensatory and social justice—reveals common characteristics shared among them. These characteristics include the capacity for social engineering, interest balancing, and pursuit of resource efficiency.
These characteristics, or metafunctions, all seem to be served on some level by federalism. But, as more than a concept, federalism looms large over state common law with the capacity to retool existing doctrine and formulate new rights and liabilities. It changes jurisprudence in matters historically rooted in medieval England or Roman city-states, alters the strategies and tactics of legal advocacy, and redefines social expectations of law in culture.
Part V below is a survey of the diverse areas in which the federalization of tort law has already taken place and a modest evaluation of the results such developments have brought. Each of these has had a concomitant impact upon legal culture—the symbols and practices employed by adjudicators, legal professionals, and laypeople involved in the following types of cases.
The first may be grouped around constitutional rights implicated through the tort system. These include, among other things, First Amendment protection of free expression and its implication in tort actions, including defamation or false light.
The current Part presents each of these areas, describing legal claims and arguments comprising each with particular interest in any common pattern to make sense of current contours of tort federalization.
Where this has been the case, state court jurisprudence has been modified by constitutional requirements to safeguard those rights. Although the relative accuracy rate of post-federalization rulings in this area remains a critical area of further investigation, this subpart presents only the main areas where fundamental rights have justified federal incursion.
The First Amendment: Defamation, Privacy, and Emotional Distress Liability for reputational and dignitary harms to the person is the clearest area in which state law doctrines have become federalized. Here, state rules have been modified by additional language meant to ensure First Amendment protection for speech. Most importantly, it will be useful to note the ambient cultural context in which such rulings arose, for therein lies the first key to assessing the propriety of tort federalization.
See N. Times Co. Sullivan, U. Sullivan, but it was later applied in speech cases brought under theories of false light, public disclosure, and emotional distress. It captures succinctly what is probably at stake in all areas of federal incursion: the proper balance between cultural uniformity and cultural alterity where alterity is manifested in the normative differences between discrete jurisdictional units or between the present and the past.
See David A. Times, U. See infra notes —58 and accompanying text. First, the element of defamatoriness was relatively subjective: it could be damaging in the eyes of a tangible community, for example, a village; a vocational community, for example, shoemakers; or a spiritual community, for example, Orthodox Jews.
Such specificity may have been appropriate under early modern conditions where community stood for something concrete, where social relations rarely crossed large geographic spaces, and where political interests tended to remain local for practical and economic reasons. But, a difficulty arose as these simple conditions evolved into more complex social realities. How, in short, could local norms as to reputational harm be applied to speech-uttering defendants operating at distances remote from the cultural milieux in which the above assessments were always made?
A litany of conditional and absolute privileges available as defenses to the common law case were already applied to this problem. The conditional privileges were those that could be raised to defeat a complete prima facie case in the absence of scienter or malice on the part of the defendant.
Gertz v. Robert Welch, Inc. Absolute privileges were those that could shield liability even for such statements made with ill intent. Among these privileges, two major themes that would have pertained to New York Times were news media and political status. That federal standard, the actual malice test, emerged in a case of unique historical and political significance. New York Times Co. Sullivan saw a claim from an Alabama police chief against a nationally circulating print media outlet for statements it published regarding his treatment of civil rights demonstrators.
More importantly, the New York Lynett, A. McCormack, U. Elsewhere under U. Similarly, the application of federal authority to tort law in defamation using the underlying civil rights fact pattern of New York Times was no coincidence.
As many have pointed out since, the purpose of the actual malice standard was not to protect harmful but easily proven true statements, nor harmful but unverifiably false statements; the former could survive a common law claim with truth as an absolute defense, while the latter was not worthy of protection a priori. Rather, the main object of the actual malice standard and new burdens was to protect harmful but unverifiably true statements—exactly those utterances that would be valuable in public criticism of segregationist or other culturally obstructionist public officials.
Brown v. Anderson, supra note , at —22, See supra notes 31—32, —05 and accompanying text. Knowledge disparities that may have once characterized early modern American society—as between working and propertied classes—were reduced. That uniformity was deeply contingent upon circumscription of insider and outsider units. The U. Its participants sought both symbolic and materialist inclusion of African-Americans through equal application of existing law and new federal legislation.
Social exclusion of nonwhites prior to Brown v. Board of Education strengthened claims about cultural uniformity across the American landscape. Even if segregation only directly impacted southern states, its survival permitted symbolic differentiation in both northern and southern regions regardless of local rules. This contradistinction required maintenance of black outsiders in order to perennially construct and maintain a uniform white insider status.
On this account, federalization of norms was not necessary to bring about uniformity. As the nation warmed to the objectives of the civil rights movement, insiders became less uniform in two respects.
First, they now included white as well as nonwhite communities. Second, the white population was divided over the cultural primacy of segregation. The first and most proximate, discussed further below, came in the form of federal preemption via legislation at the national level.
In the latter category, the actual malice standard emerged to significantly In New York Times, Justice Brennan was clearly interested in uniformity as the terminus of social change on the subject of civil rights.
The general proposition that freedom of expression upon public questions is secured by the First Amendment has long been settled by our decisions. To many this is, and always will be, folly; but we have staked upon it our all. Here, information is in the service of change, change is in the service of uniformity, and uniformity is in the service of—at least one vision of—equality.
Although not every defamation case is about underlying race relations, subsequent extension of the new standard appeared frequently to pivot on fact patterns arising amid rapid social change. First, the standard was extended from defamation analysis into the invasion of privacy torts— notably false light. See supra notes —19 and accompanying text.
Button, U. United States, U. California, U. Associated Press, 52 F. This common law rule was then supplemented by the actual malice requirement. In the seminal case Time, Inc. Hill, a private figure plaintiff sued another news media defendant for publishing photos of a reenactment of a hostage crisis in which the plaintiffs had been the victims. A second privacy tort federalized under New York Times was public disclosure of private facts.
Cohn decided in that such expression was constitutionally protected when it conveyed Jurata, Jr. Falwell that public figures must show the statement was made with actual malice. The most obvious is that they seek legal recourse for harmful acts of expression that were committed by media defendants. Furthermore, the questionable utterance in each pertains to one or another socially unacceptable behavior: racism, kidnapping, rape, and incest.
These common threads are no coincidence: the actual malice requirement is intended to protect harmful but unverifiably true statements about public Thus, in most cases where actual malice applies, the subject matter will be a socially controversial one.
But the question is why nationwide uniformity, wrought by federalization through First Amendment jurisprudence, is acceptable in this domain. The answer is culture based. Today, little has changed except that perhaps an expansion of this collective reflection on self-identity now includes notions of belonging that far transcend our national borders.
One relatively recent illustration of this open issue was the publication of cartoons by newspapers in Europe. See supra note and accompanying text. See supra notes — The Fourteenth Amendment: Public Takings and Damage Awards Outside reputational and dignitary harms, state tort law has received narrow federal influence by constitutional authority in harms to property. Here, traditional harms to property remain defined through state common law jurisprudence.
Milwaukee Mut. See Kelo v. City of New London, U. In either case, a private individual is subject to liability for conduct that satisfies the above tests.
Such conduct, of course, is defensible under the doctrines of public and private necessity. Private necessity is an incomplete privilege that avoids liability but requires payment of damages on the theory that the trespass or conversion benefitted a single or narrow group of beneficiaries. The common illustration is the stranded hiker who breaks into a wooded cabin to take shelter from a snowstorm. In one common fact pattern, an armed fugitive takes shelter in a single home within a densely occupied neighborhood.
The suspect refuses to surrender and insists on going down in a blaze of gunfire. To avoid that outcome, local SWAT officers use a bulldozer to strip the fugitive of his safe haven. Does the SWAT agency have a duty to compensate the safe but dispossessed homeowner? See Alden v. Maine, U. See Hans v. Louisiana, U. If successful, a public takings argument against governmental tortfeasors for property harm defeats these defenses. First, it may mean that the actions of the state actor constitute a deprivation of property without due process—a clear constitutional rights violation for which the state cannot claim immunity.
In some jurisdictions, a SWAT action of the kind described above amounts to an exercise of eminent domain and bars the public necessity defense.
On one hand, it reflects the influence of the well-established constitutional principle of due process in government torts. On the other, even with the split interpretations of eminent domain and police power authority, Scheuer v. Rhodes, U. See Wegner v. See Customer Co. City of Sacramento, P.
In accepting public necessity, the court rejected the eminent domain analogy: In the present case an action for inverse condemnation does not lie, because the efforts of the law enforcement officers to apprehend a felony suspect cannot be likened to an exercise of the power of eminent domain.
Conceivably, such unusual actions might constitute an exercise of eminent domain, because private property would be taken for public use. Application of the just compensation clause in the present case would mean, for example, that every time a police officer fires a weapon in the line of duty, that officer exercises the power of eminent domain over any property that the officer reasonably could foresee might be damaged as a result.
Milwaukee Mutual Insurance Co. Although not by any means limited to application in tort cases, these limits have had pronounced influence in tort cases where windfall punitive judgments might previously have stood as incentive for plaintiffs to litigate and for defendants to settle. BMW of N. Gore, U. Alliance Res. Gore, So. But the States need not, and in fact do not, provide such protection in a uniform manner. Some States rely on the judicial process to formulate and enforce an appropriate disclosure requirement by applying principles of contract and tort law.
Other States have enacted various forms of legislation that define the disclosure obligations of automobile manufacturers, distributors, and dealers. The result is a patchwork of rules representing the diverse policy judgments of lawmakers in 50 States. That diversity demonstrates that reasonable people may disagree about the value of a full disclosure requirement. Some legislatures may conclude that affirmative disclosure requirements are unnecessary because the self-interest of those involved in the automobile trade in developing and maintaining the goodwill of their customers will motivate them to make voluntary disclosures or to refrain from selling cars that do not comply with self-imposed standards.
Those legislatures that do adopt affirmative disclosure obligations may take into account the cost of government regulation, choosing to draw a line exempting minor repairs from such a requirement. Because of the different expectations on disclosure nationwide, the Alabama Supreme Court had said that a punitive award far in excess of the compensatory damage award was an undue effort to deter lawful conduct in states beyond the one at issue.
Supreme Court agreed but further took issue with the Alabama court. It assessed the punitive award according to 1 the degree of reprehensibility of the conduct; 2 the disparity between the compensatory award and the punitive award; and 3 the difference between the punitives awarded here and in similar cases.
Although the majority criticized the ratio in Gore, it stipulated that a mathematical formula as to excess amounts could not be prescribed. Campbell reached a numerical ratio guideline to determine excessive awards in cases of ordinary economic damage amounts. Supreme Court granted review. Our jurisprudence and the principles it has now established demonstrate, however, that, in practice, few awards exceeding a single-digit State Farm Mut. Federal Preemption The richest and most extensive area of tort federalization occurs in federal preemption by congressional act.
Here, multiple complex canons of doctrine and interpretation intersect to create a flexible tapestry of cooperation and disjuncture between state and federal sovereign powers. Among these arise questions of congressional intent, institutional competency, judicial efficiency, and the cultural history of American federalism itself.
Underpinning those are perhaps even deeper issues about nationhood and national uniformity in a vast geopolitical and pluralist landscape. Its language says that [t]his Constitution, and the laws of the United States which shall be made in Pursuance thereof; and all Treaties made, or which shall be made, under the Authority of the United States, shall be the supreme Law of the Land; and the Judges in every State shall be bound thereby.
As some have pointed out, anti- preemption provisions typically enjoy greater deference. Several have argued that this presumption is deployed so erratically across the case law as to be nearly unusable. Thus, in Altria Group, Inc. Good, the Court held that the Federal Cigarette Labeling and Advertising Act did not preempt a claim under a Maine trade practices law enabling a suit for fraudulent misrepresentation of cigarette smoking risks. A federal statute may overcome the presumption against preemption if it addresses subject matter, notwithstanding the absence of any explicit language to preclude a state law or claim, that would place enforcement in conflict with the state rule, or subject matter in an area of social or economic life that Congress has claimed as its domain.
Schuck, supra note 22, at See English v. See Gracia v. Volvo Europa Truck, N. See English, U. Pet Quarters, Inc. See Eric S. Under regulatory preemption, a state may be precluded from implementing its own regulatory rule over a substantive area because the federal regime has been held to expressly or impliedly preempt such action. Rather, the state is precluded from exercising its oversight.
This differs from common law tort preemption in that the latter involves decisions whether or not private causes of action can be maintained under state tort law given federal legislation or agency policy. Some have argued that this critical feature makes federal preemption of tort claims a constitutional issue.
In most instances, these acts of Congress are beyond constitutional review and assumed to fall within the ambit of Article I authorities— most commonly the commerce power.
As some have said, preemption is in many respects among the last holdouts of horizontal See Jack W. See Robert J. Lohr, 75 N. Goldberg, supra note 11, at See infra notes —56 and accompanying text. Social and Economic Activity Preemption cases have arisen around key substantive areas of national social and economic life.
Several of these areas have sedimented into detailed, nuanced canons of doctrine for when federal statutes or regulatory compliance may preclude a tort claim in state court. These canons cover, among other things, the fields of transport and aviation, food and drug, environmental protection, and labor relations.
In proposing a federalism function to tort law, we must understand the role state court adjudicators play in finding that tort suits in these areas are preempted.
This is a different goal than assessing the propriety of any one preemption decision. Thus, automobile safety requirements should probably remain uniformly reliable across state boundaries first because the products themselves are made and sold in different places, second because once sold they carry people and goods across these lines, and third because they make use of and interact closely with the interstate highway system.
Gluck, supra note 17, at American Honda Motor Co. Mazda Motor of America, Inc. There, a unanimous court upheld the findings in Geier that neither an express preemption clause nor a savings clause would dispose of conflict preemption, but it found that the state court See Jerry L. ON REG. And, like the tort suit in Geier, the tort suit here would restrict that choice.
But unlike Geier, we do not believe here that choice is a significant regulatory objective. In common law tort claims, this most directly affects application of an airline standard of care. Instead, there are a variety of fact-specific jurisdictional interpretations over, inter alia, safety standards for pilot training and conduct, overhead luggage storage, and adequate warnings in situations of air turbulence.
American Airlines, Inc. Williamson v. Mazda Motor of Am. Michael J. Pan Am. Express, Inc. Holland, supra note , at 18—19 citing Margolies-Mezvinsky v. Air Corp. A , WL E. Airlines, Inc. Food and Drug Food and drug safety is a second axis around which federal preemption cases have clustered.
This is likely because the sector is so pervasive, covering some twenty-five percent of U. Classically, harm from food and drug products has been recoverable under state negligence and See Elassaad v.
Independence Air, Inc. See Sakellaridis v. Polar Air Cargo, Inc. Holland, supra note , at 23 In Levy v. Continental Airlines, Inc. Levine reached the Supreme Court. Safeway Stores, Inc. See infra notes —99, —28 and accompanying text. Wyeth v. Lohr, U. As she explained, Back in , my husband and I started a label, called Rebop Records, which I did to combine my passion for music and songwriting, and my love for kids. I played bass, guitar and piano.
The label was designed to provide rock and roll that kids and parents could enjoy together. Wyeth, U. Levine v. Wyeth, No. The trial judge denied the motion for judgment as a matter of law requested on the basis of conflict preemption. It did not mandate a particular replacement warning. The first still fell short for reasons outlined by the trial and Vermont Supreme Courts. Stevens fixed upon 21 C.
Whereas the FMVSS in Geier had prescribed a specific range of passive safety restraint systems, leading the Court to infer congressional intent to promote this variety over and above a state-specific definition of defect, the FDA regulation and amendments did not prescribe any specific language for drug labeling and rather prescribed only labels that were adequate.
Davidowitz, U. The FDA has limited resources to monitor the 11, drugs on the market, and manufacturers have superior access to information about their drugs, especially in the post-marketing phase as new risks emerge.
State tort suits uncover unknown drug hazards and provide incentives for drug manufacturers to disclose safety risks promptly. They also serve a distinct compensatory function that may motivate injured persons to come forward with information. Text on this page is printable and can be used according to our Terms of Service. Any interactives on this page can only be played while you are visiting our website. You cannot download interactives.
Freedom of religion is the idea that people have the right to practice the faith of their choice. The founding fathers had this in mind when they added the First Amendment to the U. S Constitution in the Bill of Rights. Select from these resources to teach your students about the freedom of religion.
National Geographic resources support the teaching of geographic thinking, science, culture, mapping, exploration, and storytelling. This collection contains resources to provide learners with background knowledge as they explore issues related to justice, diversity, equity, and inclusion.
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Every few years, governments count the people living in their territories, a process called a census. These counts help decide how best to allocate resources and determine political representation. Learn about the surprisingly ancient origins of the census and why this counting process is important to this day.
Use the MapMaker Interactive to explore linguistic diversity across the globe today. Christine Lee is an anthropologist who specializes in bioarchaeology, which uses biological techniques to learn about ancient humans and their culture through the study of their skeletons.
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